Letter from CCOF Chair and CEO on Hydroponics and Livestock Certification

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Date

Date Published: 
April 22, 2019
Dear CCOF Member,
 
Transparency. Respect. The democratic process. We read these values out loud at every CCOF governance meeting, staff meeting, chapter meeting, and annual meeting. We remind ourselves of these values throughout the year because it takes diverse perspectives and collaboration to create a world where organic is the norm.
 
In the spirit of open collaboration, we are writing to clarify how and why CCOF Certification Services, LLC certifies hydroponic, container, and large-scale livestock operations. We are confident in our work and strive to provide leadership in the certification of these complex systems. We are providing the following information so that you have the facts about CCOF.  
 
CCOF is a nonprofit organization dedicated to advancing organic agriculture for a healthy world. Our organization was founded by and for organic producers. Today, we remain proud of and open about our governance structures, financials, organizational policies, partnerships, and commitment to giving back through grants and programs for organic producers. 
 
We are also proud to carry forth CCOF’s rich legacy of organic integrity and leadership. CCOF Certification Services, LLC is a nonprofit, USDA-accredited organic certification agency. As a nonprofit, all revenue from certification and inspection fees are reinvested back into achieving our mission. Our primary investments include staff and technologies that allow us to provide personable, accessible certification services that meet your diverse production needs. 
 
CCOF always has your back. CCOF advocates for organic farmers, ranchers, and processors and participates in the National Organic Standards Board process to continually improve organic standards. We welcome feedback and encourage you to participate in CCOF chapter meetings, to submit comments and questions to ccof@ccof.org, and to contact CCOF leadership or governance boards directly. Our annual membership meeting always includes an open discussion forum with leadership. We invite you to attend the 2020 Annual Meeting on February 19 in Sacramento, California to join the conversation.
 
You can also find more information about CCOF’s multi-faceted work through our 2017 Annual Report, our online directory, our online certification forms, and our public comments.
 
Please know that CCOF remains deeply committed to serving you and the organic community. We hope that you will help us sustain a culture of respect and mutual appreciation as we all work together to advance organic agriculture for a healthy world. 
 
Sincerely, 
Phil LaRocca
Chair, CCOF, Inc. Board of Directors
 
Kelly Damewood
CEO, CCOF, Inc. 
Chair, CCOF Certification Services, LLC Management Committee 

Facts about Hydroponics
Why does CCOF Certification Services, LLC certify hydroponic operations? 
CCOF Certification Services, LLC certifies hydroponic operations because they are allowed by the USDA National Organic Program (NOP). If the NOP allows a type of production system, then a USDA-accredited certifier cannot deny certification to a producer using that production system based on philosophy or values alone. This is a requirement set forth in certifiers’ operating agreements. CCOF Certification Services, LLC sought clarification from the NOP about whether hydroponic systems were allowed in organic production when it first received an application from a hydroponic producer over a decade ago. The NOP’s position then, as it is now, is that hydroponic systems are allowed in organic production. 
 
Why do some organic certifiers certify hydroponic operations, and some do not?
Certifiers may decline to certify certain production systems if they lack the appropriate technical or administrative capacity to do so. Certifiers cannot deny certification based on philosophy or values alone. Certifiers that do not certify hydroponic operations have informed the NOP that they do not have the technical or administrative capacity; they are not denying certification because they have different values than CCOF Certification Services, LLC or any of the other certifiers who offer certification to hydroponic producers. 
 
So far, CCOF Certification Services, LLC has demonstrated the technical expertise to certify hydroponic systems, and we continue to monitor our administrative capacity to serve these complex systems. To maintain its federal accreditation, CCOF Certification Services, LLC must follow rigorous auditing and verification procedures, including compliance with the requirement that certifiers do not deny operations certification based on philosophy or values alone. 
 
Some certifiers state that they do not certify hydroponic systems when they do certify container systems. The USDA organic standards do not define hydroponic systems, and a wide spectrum of container-based systems are used in organic production. Opinions differ on what makes a container system a hydroponic system, and many stakeholders consider container systems using certain substrates to be a version of hydroponic systems. Regardless, both types of systems are allowed under the USDA organic standards. 
 
CCOF Certification Services, LLC certifies fewer than ten operations with hydroponic systems that have roots in water and over 100 operations that use a range of container-based systems with roots in a substrate (an increasingly common type of operation certified by many different organic certifiers). 
 
How does CCOF Certification Services, LLC certify hydroponic operations?
All organic producers, including hydroponic and container operations, must submit an Organic System Plan, undergo an annual inspection, use only allowed inputs, and implement practices that foster biodiversity and protect natural resources. 
 
CCOF Certification Services, LLC is as rigorous in applying the national organic standards to hydroponic operations as to soil-based operations. Hydroponic and container operations must provide a detailed description of their production system. This description must explain the biological activity in their system, whether their system contains organic matter sufficient to support biological activity, and how nutrition is available to their crops. Additionally, any spent growing media must be managed in a way that does not contribute to contamination or degradation of natural resources. 
 
CCOF Certification Services, LLC does NOT allow the use of glyphosate or other prohibited materials in container production. Producers using container systems must manage their entire parcel organically. This includes sourcing organic seed for in-ground planting within parcel boundaries (with a documented seed search if non-organic seed is used), diversified plantings, maintaining or improving soil health and natural resources, and only applying allowed materials.
 
What is CCOF’s organizational policy position on the allowance of hydroponic systems? 
CCOF Certification Services, LLC is a wholly owned subsidiary of CCOF, Inc., which is governed by a board of directors made up of member-elected organic producers. Recognizing that hydroponic systems have long been allowed in organic production, CCOF, Inc.’s position is that NOP should clarify standards for these systems and require a “hydroponically grown” or “container grown” labeling statement
 
We understand and empathize with members of the organic community who strongly believe that hydroponic systems do not align with the origins of the USDA organic label. We understand and empathize with the position that a crop cannot be organic unless the crop was grown with its roots in soil (as opposed to roots in water or roots in some type of substrate or container). 
 
We also understand and empathize with longtime CCOF members who have been using hydroponic systems and with organic producers who are seeking to incorporate the benefits of hydroponic systems (like water and labor savings) into their operations. 
 
As a middle path solution, CCOF continues to advocate for transparency in production practices. We support adding a standard to the USDA organic regulations that would require a “hydroponically grown” or “container grown” labeling statement. We have also proposed clear standards for hydroponic and container production systems, which would affirm that these systems must include biological diversity, nutrient cycling, and microbial activity, as well as require the entire crop production site to be managed organically. Our full proposal to the NOP on hydroponic and container systems may be read on our website.
 
CCOF’s proposed clarifications for hydroponic and container standards are intended to be a conversation starter; the proposed standards are not our final and complete view on the future of hydroponic and container standards. We have always advocated for the opportunity to discuss standards for these complex systems with the broader organic community.
 
What’s next for hydroponic and container production? 
NOP has affirmed their longstanding practice of allowing hydroponic and container systems under the USDA organic standards. If asked to join in partnership with other members of the community, CCOF would eagerly be at the table to help clarify standards for these complex systems. 
 
As an accredited certifier, CCOF Certification Services, LLC cannot require a “hydroponically grown” or “container grown” label unless it is required by the NOP. We strongly encourage CCOF members using container-based practices to consider how they can provide transparency about these practices through a labeling statement or information on their website. 
 
Facts about Livestock Certification
Does CCOF Certification Services, LLC restrict the number of animal units on a certified operation?
No. The USDA organic standards do not restrict the number of animal units allowed on an operation. CCOF Certification Services, LLC has the technical capacity and expertise to verify that livestock operations of any scale are in compliance with the USDA organic standards. 
 
All certified organic livestock operations, regardless of size, are required to comply with all applicable sections of the USDA organic standards. CCOF Certification Services, LLC trains inspectors to identify problems with pasture access or availability, temporary livestock confinement, manure management, or other issues. If an issue is identified, possible actions range from issuing a noncompliance to proposing suspension or revocation of certification. In other words, operations can and will lose certification they are not in compliance with the USDA organic standards. 
 
How does CCOF Certification Services, LLC oversee large herds?
CCOF Certification Services, LLC ensures that even large herds or herds in dry regions have sufficient access to pasture. In addition to the standard annual inspection, CCOF Certification Services, LLC designed two additional inspections for livestock operations: the Livestock Unannounced Compliance Initiative (LUCI) and the Pasture Compliance and Feed Audit (PCFA)
 
CCOF pioneered the LUCI in 2008, which administers an unannounced pasture-based inspection to observe the quality and quantity of pasture during the grazing season and to watch animals being moved through the paddocks and to and from the milk barn. 
 
In 2018, CCOF launched the PCFA, which is a records-focused inspection for operations of a particular size or complexity, or operations that have areas of concern with relation to pasture availability, feed, and/or dry matter intake from pasture. 
 
How has CCOF weighed in to clarify livestock standards?
CCOF strongly supported the USDA’s Organic Livestock and Poultry Practices rule, which was unfortunately rescinded by the current federal administration. We submitted comments and letters of support for the rule and consistently advocated for strict organic livestock standards. A sampling of our work on this issue is available on our website.
 
CCOF is a strong advocate for firm livestock standards that align with the intent of the rule and consumer expectations. CCOF has always required and will continue to require outdoor access areas for poultry that include contact with soil. CCOF has never allowed the use of “porches” to meet this requirement. 
 
CCOF also submitted comments throughout the development of the Origin of Livestock rule, a proposed regulation that was also rescinded by the current federal administration. The rule clarified how animals can transition into organic production. It would have given certifiers clear language to provide consistent enforcement and the ability to deny some transition requests.  
 
CCOF helped our members submit letters of support for the proposed rule to USDA Secretary Sonny Perdue and NOP leadership. CCOF has also signed onto letters with other organic organizations on implementing strict organic livestock rules.
 
Other Facts about CCOF
The CCOF Foundation invests in the education of new organic farmers and producers, helps consumers understand the benefits of organic, assists organic farmers in need, and provides ongoing training for organic professionals. The CCOF Foundation has granted over a half million dollars to new organic farmers and ranchers since 2014.
 
CCOF’s policy team played a critical role in building bipartisan support to advance 2018 Farm Bill policies that strengthen NOP enforcement, increase funding for organic research, and protect the National Organic Cost Share program. 
 
CCOF Certification Services, LLC is a member of the Accredited Certifiers Association (ACA), an association of USDA-accredited organic certifiers. CCOF Certification Services, LLC is an active participant in many ACA Working Groups to develop consistent, sound, and sensible organic certification policies and practices with certifiers from around the world. Additionally, a CCOF Certification Services, LLC staff member serves on the ACA Board of Directors. 
 
CCOF Certification Services, LLC is the proud recipient of the 2018 and 2019 NOP Investing in INTEGRITY Award, which recognizes CCOF Certification Services, LLC for its contributions to the Organic Integrity Database and commitment to providing accurate, timely, and comprehensive data reporting to the database.
 
CCOF works with a range of organizational partners to achieve our mission, including serving as a strategic partner of the Organic Trade Association (OTA), a network affiliate of the National Organic Coalition (NOC), an organizational member of the Organic Farmers Association (OFA), a represented member of the National Sustainable Agriculture Coalition (NSAC), and an associate member of the Santa Cruz County Farm Bureau
 
For more information about CCOF, visit www.ccof.org or contact us at ccof@ccof.org.